Particulars

Requirement

Threshold Limit

Trigger Event

Disclosure To

Timeline

Remarks / Notes

Initial Disclosure (Reg. 29(1))

Any acquirer (along with PAC) acquiring shares or voting rights which taken together aggregates to 5% or more of the shares/voting rights in a target company.

≥ 5% (or ≥ 10% for IGP-listed entities)

On acquisition reaching or exceeding threshold

(a) Stock Exchange(s) where shares are listed; and 

(b) Target Company at its registered office

Within 2 working days of allotment or acquisition

Form as prescribed by SEBI

Continual Disclosure (Reg. 29(2))

Any person (with PAC) holding 5% or more shares or voting rights, shall disclose any change in such holdings ≥ 2% (of total shareholding or voting rights) since last disclosure (under sub-reg. (1) or (2)).

Holding ≥ 5% (or ≥ 10% for IGP) and change ≥ 2% (or ≥ 5% for IGP)

On change in shareholding or voting rights, even if holding falls below threshold

(a) Stock Exchange(s); 

and (b) Target Company

Within 2 working days of change or intimation of allotment/disposal

Applies for both increase and decrease in holdings

Encumbrance Treatment (Reg. 29(4))

Shares taken as encumbrance = treated as acquisition; Shares released from encumbrance = treated as disposal

N/A

On creation or release of encumbrance

(a) Stock Exchange(s); 

and (b) Target Company

Within 2 working days

Disclosure not required for scheduled commercial banks, PFIs, housing finance companies, or systemically important NBFCs acting as pledgees in the ordinary course of business

Exemption (Explanation to Reg. 29(4))

Exemption applies to: 
• Scheduled commercial banks 
• Public financial institutions 
• Housing finance companies (registered with NHB, deposit taking or asset size ≥ ?500 crore) 
• Systemically important NBFCs (as per ICDR Regulations)

N/A

When acting as pledgee

N/A

N/A

Regular encumbrance-related disclosures not applicable to these entities